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FTC Adopts Data Breach Notification Obligations for Non-Banking Financial Institutions

On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...more

Guidance for the ‘Burden of Cybersecurity Compliance’ Emerges

Two months ago, the White House released its National Cybersecurity Strategy.  Since then, various government agencies have issued new cybersecurity guidance for certain critical infrastructure subsectors.  For example, the...more

Federal Banking Regulators Issue New Guidance for Complying with 36 Hour Cybersecurity Incident Reporting Requirement

On March 29, 2022, federal banking regulators issued important guidance for how banking organizations can comply with the upcoming requirement to notify regulators within 36 hours of ransomware or other disruptive...more

Federal Banking Regulators Issue Rule Requiring 36 Hour Notice of Ransomware and Other Disruptive Cybersecurity Incidents

On November 18, 2021, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued a joint final rule to require banking...more

New York Amends Data Breach Notification Law and Enacts Data Security Protections

On July 25, 2019, New York Governor Andrew Cuomo signed the Stop Hacks and Improve Electronic Data Security Act (the “SHIELD Act”), making key changes to New York’s data breach notification and cybersecurity laws....more

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